This is part of a detailed look at several actions that the Department of Transportation (DOT) took last Friday to reduce the hazards associated with the transport of crude oil and other flammable liquids by train. Earlier posts in this discussion include:
This post looks at a joint Safety Advisory published by the Pipeline and Hazardous Material Safety Administration (PHMSA) and the Federal Railroad Administration last Friday (and it is scheduled to be published in the Federal Register tomorrow).
The SA reminds railroads that the FRA and PHMSA have authority to investigate railroad accidents, particularly those involving hazardous material. As part of that investigation process they have the legal authority to demand information from the railroad and affected shippers of hazardous materials. As a matter of advance notice, the SA provides a list of the type of information that they routinely expect to request for accidents involving crude oil train cars or other flammable liquid accidents. Those include:
∙ Information on train consist;
∙ Safety Data Sheet;
∙ Results of product testing used to categorize flammable material;
∙ Results of product testing of railcar samples;
∙ Date of Acceptance;
∙ Company extracting crude oil;
∙ Company doing initial categorization testing;
∙ Company hauling crude oil or other flammable liquid to loading facility; and
∙ All railroads handling affected railcars;
The ‘train consist’ information would include:
∙ Train number;
∙ Locomotives as distributed power;
∙ End-of-train device information;
∙ Number and position of tank cars in the train;
∙ Tank car reporting marks;
∙ Tank car specification and ‘relevant attributes’
A lot of the product related information included in the above list is going to be unique to crude oil shipments because of the increased testing in the latest version of EO 28 issued last year. Manufacturers of flammable liquids do not have to test every load to confirm the classification and packing group of the material. They can use standard information on the product. The oil industry used to be able to do this, but spot checks by PHMSA indicated that there were a number of cases where those assumptions were wrong.
At this time this information is only needed on an ‘on demand’ basis in the event of a rail accident involving crude oil or other flammable liquids (mainly targeting ethanol, but that distinction is not made in this SA). It seems likely that at some point FRA will consider a formal documentation requirement for all crude oil railcars from point of extraction to delivery to the refiner.